BT's response to "CALLS TO 0845 AND 0870 NUMBERS: REVIEW OF RETAIL PRICE AND NUMBERING ARRANGEMENTS"

BT's response to Ofcom's statement and further consultation regarding - Calls to 0845 and 0870 numbers: Review of retail price and numbering

Executive summary

1. BT recognises that the decision on linking 0845 and 0870 tariffs to rates for geographic calls is but one part of reforming the NTS regime.  Additionally, until the work on that is completed, BT sees Ofcom's proposal as an interim measure, albeit a very substantive one.

2. BT welcomes Ofcom's decision not to adopt Option 2, which had great potential to be very damaging for consumers and SPs/ISPs, because of the potential for covert tariff changes to blocks in use.  BT is pleased that the status quo has been maintained in 0870/0871. 

3. BT believes that Option 1b as originally proposed by Ofcom was satisfactory for consumers and SPs/ISPs, with some down-side for the industry.  However, the modification that Ofcom has introduced in this Statement, to allow terminators to change the tariff of their blocks, has not been subject to consultation and seems to re-introduce the shortcomings of Option 2 referred to above.  Given the apparently insurmountable difficulties in being able to adequately notify all interested constituencies of a proposed tariff change, the modification that Ofcom has latterly proposed would appear to have one of two possible following outcomes. 

4. If the terminating company takes advantage of the ability to change tariff, it is likely to materially damage SPs/ISPs and consumers. 

5. If it believes it cannot do so because of the aforementioned hurdles, the modification becomes largely irrelevant.

6. BT would therefore urge Ofcom to re-think their decision to allow tariff changes to blocks in service.

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Comments should be addressed to Howard Erdunast by e-mail to howard.erdunast@bt.com